Disciplinary outcome: Shabbir Musaji

1. He failed to carry out and/or document an adequate firm-wide money laundering risk assessment in contravention of Regulation 18 of the Money Laundering Regulations 2017.
2. He failed to have in place adequate Anti-Money Laundering policies, procedures and controls in contravention of Regulation 19 of the Money Laundering Regulations 2017.
3. He failed to have any or any adequate procedures in place for reporting discrepancies in the Persons with Significant Control register in contravention of Regulation 30 of the Money Laundering Regulations 2017.
4. He failed to carry out any or any adequate regular review of his Anti-Money Laundering policies, procedures, and controls in contravention of Regulation 21 of the Money Laundering Regulations 2017.
5. He failed to carry out any or any adequate client due diligence and verification in respect of one or more clients in contravention of Regulations 27 and 28 of the Money Laundering Regulations 2017.
6. He failed to carry out an adequate risk assessment and ongoing monitoring in respect of one or more clients in contravention of Regulation 28 of the Money Laundering Regulations 2017.
7. He failed to issue any or any adequate letters of engagement to one or more clients in contravention of AAT’s Client Care Policy.

By reason of the conduct set out in the Allegations above, Shabbir Musaji is guilty of misconduct pursuant to Article 21 of AAT’s Articles of Association.

The Investigation Team orders that Shabbir Musaji is:

1. Fined £3,500.00
2. Severely reprimanded for a period of two years.

The decision of the Investigations Team shall stand as an Order of the Association pursuant to Regulations 5.2 and 5.3 of the Disciplinary Regulations.